On August 2, 2023, Michele Weiss, Principal at Holtz, Slavett & Drabkin, interviewed Erin Collins, the IRS National Taxpayer Advocate.  The interview was a Beverly Hills Bar Association program.  The Taxpayer Advocate Service (TAS) is an independent organization within the IRS and is taxpayers’ voice at the IRS.  TAS helps taxpayers whose problems are causing financial difficulty, including businesses and individuals.  A taxpayers can be eligible for TAS assistance if the taxpayer has tried to resolve their tax problems through normal IRS channels and have gotten nowhere; or, the taxpayer believes and IRS procedure is not working as it should.  A taxpayers who qualifies for TAS assistance will have an advocate assigned to them who can help the taxpayer navigate their particular dilemma with the IRS.

Michele interviewed Ms. Collins about numerous topics of interest including how TAS sees the IRS using its increased funding pursuant to the Inflation Reduction Act, assistance/guidance for taxpayers who may have improperly claimed the Employee Retention Credit, and where the IRS is headed with assessment and collection of foreign information reporting penalties in light of the recent Tax Court decision in Farhy v. Commissioner, 160 T.C. No. 6 (2023).

Ms. Collins requested information from practitioners.  She is seeking situations in which taxpayers, who are not wealthy, have been charged with foreign information reporting penalties.  She is seeking this information to try to convince members of Congress that these penalties are not only assessed against wealthy taxpayers.  She requested that practitioners that are aware of such situations, to please email her at erin.collins2@irs.gov.

The interview with Ms. Collins was not recorded and is no longer available.

Holtz, Slavett & Drabkin, APLC is a tax controversy and tax litigation law firm consisting of former IRS attorneys.  We represent taxpayers in all aspects of tax disputes with the IRS and state tax authorities, including sensitive IRS audits, criminal investigations, tax litigation, and tax collection matters.  To schedule a consultation, please contact us at (310) 550-6200 (Los Angeles office) or (949) 999-6606 (Orange County office).